HRS 0651C- ANNOTATIONS

Where a creditor alleges a fraudulent transfer of property from a judgment debtor to a transferee who retains title to the subject property or who claims an interest in the property or its proceeds, the transferee is a necessary party to any action seeking to set aside the transfer. Such an action for relief against a transfer alleged to be fraudulent should be brought pursuant to this chapter, and should expressly name as defendants the alleged fraudulent transferees. 76 H. 32, 868 P.2d 450.